The Site Remediation Reform Act, Ten Years Later

A Decade of Success and a Pattern for the Future

By Caryn L. Barnes, LSRP, PG, President, LSRPA On Mar 4, 2019

Ten years ago, New Jersey took a bold step to expedite the clean up of contaminated sites, address the impacts of its industrial past, and embrace a new process for the future.

The Site Remediation Reform Act (SRRA) of 2009 created a new paradigm for cleaning up sites and protecting people and the environment. SRRA established an affirmative obligation to clean up releases and created a new category of professionals, the Licensed Site Remediation Professional (LSRP).

The LSRP’s role is to guide responsible parties, property owners and developers through the process of remediating sites, in accordance with the New Jersey Department of Environmental Protection’s (NJDEP’s) rules, regulations and guidance. With limited exceptions, under SRRA, the NJDEP’s role shifted from case management to inspection and review, while LSRPs, using professional judgment, determine when closure is appropriate for a site.

The program works! According to NJDEP’s statistics, more properties are being cleaned up than ever. More than 13,000 closure documents or Response Action Outcomes (RAOs) have been issued by LSRPs to date.

Cleanups also are faster. From 2001 and 2008, NJDEP case managers closed approximately 3,000 cases. In the first eight years following SRRA, 2009 to 2016, more than 6,000 cases were closed by LSRPs.

These weren’t just the simple sites. Pre-SRRA, 31 percent of the closures were complex sites; sites with complicating factors such as multiple impacted media, comingled contamination, or complex geology. Post-SRRA, this percentage increased to 37 percent.

During this time, both the program and the profession of the LSRP have matured. The mission of the stakeholders – the regulated parties, the NJDEP, the LSRPs, and the communities – remains the same: protection of human health and the environment.

Stakeholder input, which the NJDEP embraces, is extensive through advisory groups; comments about guidance documents, regulations and standards; and education and training. The Licensed Site Remediation Professional Association (LSRPA) provides its input on a quarterly basis with the leadership of the NJDEP and other stakeholder processes.

Professionally, the LSRPs have become vital to the responsible parties. The number of LSRPs also has continued to grow, now at 709, supporting a healthy succession plan for replacing retiring professionals.

As you will read in the following section, the LSRPs are constantly re-examining their role and their work to achieve better outcomes, and tackling diverse technical challenges every day.

The LSRPA is proud to represent these highly educated, conscientious and hard-working professionals. The LSRPA’s primary goal is to advance the profession of LSRPs, through training, information, and technical resources to our membership, as well as promoting the standards of care and use of professional judgment when protecting public health, safety and the environment.

Radical candor – open and respectful – has helped the parties involved create a formula for environmental success over the past 10 years. This same trust and openness will foster our successes over the next decade.

Sincerely,

Caryn L. Barnes, LSRP, PG

President, LSRPA

Caryn L. Barnes is a Principal with Langan Engineering. She leads the environmental practice in Langan’s Center City, Philadelphia office

 

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